1:18-Cv-06723 Document #: 1 Filed: 10/04/18 Page 1 of 52 Pageid #:1
Case: 1:18-cv-06723 Document #: 1 Filed: 10/04/18 Page 1 of 52 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS Chicago Division BRIGHTER SKY PRODUCTIONS, LLC, and ) DAN TRAMON, and ) DIANA BELKOWSKI, and ) CARL ANTHONY TRAMON, ) ) Plaintiffs, ) ) v. ) Case No. 18-6723 ) MARRIOTT INTERNATIONAL, INC., and ) BRE DIAMOND HOTEL HOLDINGS, LLC ) as the surviving company of a merger with ) STRATEGIC HOTELS & RESORTS, INC. ) d/b/a MARRIOTT THEATRE, and ) DEMAND FOR JURY TRIAL BRE DIAMOND HOTEL HOLDINGS, LLC, and ) BRE DIAMOND HOTEL, LLC ) a wholly owned subsidiary, and ) DTRS LINCOLNSHIRE, LLC, and ) RFMBG, LLC; and ) LA-RFMBG LINCOLNSHIRE, LLC ) d/b/a Marriott Theatre, and ) MARRIOTT HOTEL SERVICES, INC., and ) STRATEGIC HOTELS & RESORTS, LLC, and ) MICHAEL MAHLER, and ) AARON THIELEN, and ) TERRY JAMES, ) ) Defendants. ) COMPLAINT Plaintiff Brighter Sky Productions, LLC (“Plaintiff Brighter Sky”), Plaintiff Dan Tramon (“Plaintiff Dan Tramon”), Plaintiff Diana Belkowski (“Plaintiff Belkowski”) and Plaintiff Carl Anthony Tramon (“Plaintiff Carl Tramon”) (collectively “Plaintiffs”), by and through their undersigned attorneys, based upon actual knowledge with respect to their own acts and upon knowledge, information and belief with respect to all other matters, allege as follows: Case: 1:18-cv-06723 Document #: 1 Filed: 10/04/18 Page 2 of 52 PageID #:2 NATURE OF THE CASE 1. This is a civil case that arises to remedy the unlawful actions taken by Defendants, in part with the assistance of their co-conspirator, Universal Pictures, a division of Universal City Studios, LLC (“Universal”), as they relate to Plaintiffs’ musical Rocket Boys (the “Rocket Boys Musical”) which is based on the #1 New York Times bestselling book Rocket Boys: A Memoir (the “Rocket Boys Book”) written by world-renowned author Homer Hickam, Jr.
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